Your information. Handled with care.

Who is responsible

Panuma is operated by Reza Taghizadeh.

Contact address: Stübeheide 9, 22337 Hamburg, Germany

Contact: info@panuma.app, or use our support form.

The operator is the controller for Panuma’s own adult account, enquiry and service-security processing. A treating therapist or clinic is responsible for the care purposes it determines, the information it supplies and its own clinical records. See our legal notice for the operator’s contact details.

Information we use

• Adult account details: name, email, account role, password hash, verification records and device/session identifiers.
• Enquiries: name, email, message, request type, preferred weekday where relevant, contact permission and request status.
• Child profiles and plans: nickname or display name, date of birth, therapist/caregiver relationships, assigned activities and their settings. A therapist can create a profile and plan activities before the separate recording-consent step.
• Consent evidence: the signer’s first and last names, declared relationship and authority, drawn signature or typed-name confirmation, exact notice and version, child and therapist identifiers and name snapshots, and signing or withdrawal times.
• Recorded practice: exercise duration, game and assignment, attempt and session identifiers, timestamps, submitting adult/device, home or clinic setting, application/runtime version and age in months derived from date of birth. Where the signed notice permits practice results, sessions that are completed or explicitly finished early may also include the total numbers of correct and incorrect responses and accuracy calculated from those totals. For Find the Fruit, we also record the selected timed or question-count mode, its duration or question limit, the chosen conflict percentage and whether the session was completed, reached its time limit or was finished early. In this game, unanswered questions are not counted as incorrect responses. Earlier duration-only consent does not enable response counts. We do not collect clinical assessments, behaviour notes or raw response traces through these result forms.
• Service records: network and device information, access and security events, request identifiers, response status and technical diagnostics. If enabled, billing records include subscription/payment/refund references and amounts; file or game-idea submissions include the supplied content and upload metadata.

We receive information from the adult using Panuma, a connected therapist or caregiver, and service interactions. A nickname is not anonymous when linked to a date of birth and adult relationships. Please avoid unnecessary child or health details in support messages and uploaded files.

Purposes and legal bases

For adult account services and steps you request before entering a contract, the basis is Article 6(1)(b) GDPR. Service security and abuse prevention rely on our legitimate interest in protecting accounts and service reliability, subject to your rights, under Article 6(1)(f). Where a specific legal duty requires processing, Article 6(1)(c) applies.

For optional recording and sharing of a child’s practice, we request the separate signed consent described in that workflow under Article 6(1)(a), and explicit consent under Article 9(2)(a) where the information is health data and that basis is legally available. An adult account contract or a security interest alone does not authorise processing child health data. Before entering profile or planning information, the responsible professional must establish a lawful basis for that use and, for health data, an applicable Article 9 condition. The professional must explain its care-related processing to the family; Panuma’s recording-consent step does not replace that responsibility.

Contact permission for an enquiry is permission to respond to that request, not a marketing subscription. Account information is needed to provide sign-in and connected services; without it, those services cannot be provided. Optional practice recording can be declined without treating that choice as agreement to record. You can read the GDPR for the underlying rules.

Children and recording choices

Adult accounts manage children’s activities. Profile creation and activity planning are separate from permission to record performance. Recorded practice requires active consent and an authorised connection; account verification alone does not establish guardianship. The signature records the adult’s declaration and choice, not an independent identity check.

Unsaved play does not upload child performance, although account checks and technical delivery requests still occur. With active consent, an authorised connected therapist can review the permitted practice history: exercise timings and, where the signed notice includes them, aggregate response counts and accuracy charts. These charts describe recorded activity and are not a clinical assessment. Caregiver accounts can submit permitted practice but do not receive that history.

The signing caregiver can withdraw recording consent through the family workflow or contact us for help. Withdrawal stops future recording and sharing under that consent, including pending uploads, without changing the lawfulness of earlier consent-based processing. It does not automatically delete the profile, earlier records or consent receipt. The signer can still access their receipt.

Therapists, clinics and other recipients

Access follows the user’s role and authorised relationship. The treating professional remains responsible for care decisions and any separate clinical recordkeeping duties. Where a clinic determines the purposes of patient-information processing, it is responsible for those purposes and for informing the family. Processing on behalf of a clinic requires its documented instructions and any agreement required by applicable law. This notice and the family’s recording consent do not replace those arrangements.

Authorised service operators and hosting providers may process information needed to operate and protect Panuma. Information may also be disclosed when a specific legal requirement applies. A clinic’s independent records and privacy notice may differ from Panuma’s; contacting us does not automatically delete records held separately by the clinic.

Hosting and external services

The application database is hosted on a Contabo server in Germany. We use Hostinger Email for account verification, password-reset and family-invitation messages, and for correspondence through info@panuma.app. Hostinger processes email addresses, message content and delivery metadata needed for these communications. Delivery also involves the recipient's email provider. Email processing locations depend on these providers and may include countries outside Germany or the European Economic Area. Hostinger's published Data Processing Addendum describes its transfer arrangements, including EU Standard Contractual Clauses where applicable; its privacy policy explains international processing. Contact us for further information about the arrangements relevant to your request. We use Cloudflare R2 to store and deliver game files, illustrations and educational resources, and to store attachments submitted with content suggestions. Cloudflare processes file contents and technical request data needed for storage and delivery. Do not include identifiable child information in content suggestions or attachments. We do not claim that all Cloudflare processing takes place in Germany. Contact info@panuma.app for information about the processing arrangements. Stripe payments are not enabled in this deployment. No routine off-host backup service is configured.

If hosted card checkout is enabled, card details will be entered with the payment provider rather than in a Panuma support form. We will identify the enabled provider and relevant processing before that feature is available.

Retention and deletion

Retention depends on why a record is needed: providing the account or active care connection, resolving an enquiry or dispute, demonstrating a consent choice, protecting the service, and meeting a specific applicable legal recordkeeping duty. A clinic’s own duties do not automatically determine how long Panuma may keep every record.

The current service does not automatically erase accounts or child records on a fixed schedule. Retention and deletion requests are reviewed individually. We consider whether the account or care connection is still needed, whether an enquiry or dispute is resolved, whether consent evidence is needed to explain past processing, and whether a specific legal obligation requires a record to be kept. Records that no longer have a lawful purpose must be deleted or anonymised. Contact us to request a review; we will explain any retained categories and the reason.

Archiving a child, withdrawing consent and cancelling a subscription preserve existing records. They are separate from an erasure request. We will explain any records that must be retained and the reason when responding. Expiry of a sign-in token or invitation prevents its use; it does not by itself mean every related database record is erased.

Cookies and browser storage

Account and family areas use HTTP-only cookies for sign-in, verification, recovery, invitations and selected plan details. Session cookies last up to 30 days; device-identifier cookies last one year. Verification and recovery cookies are short-lived. Family clinic sessions are limited to 15 minutes; completed invitation state may remain for up to 30 days outside clinic mode.

The therapist workspace also saves browser-only child profiles, dates of birth, selected activities and invitation details, including the caregiver email, in persistent browser storage called IndexedDB. These records are not just held in memory and are not automatically cleared by signing out. Removing a local profile does not necessarily remove separate invitation storage; clearing that site’s browser data removes local copies but not server records. Family pages use a local-storage timestamp to coordinate session changes across tabs.

The current web service uses no advertising or audience-analytics tools. Necessary service and security processing still occurs. If optional tracking is introduced, we will explain it and obtain any required permission before use.

Your rights

Where the GDPR applies, you may request access and a copy, correction, erasure, restriction, and data portability where its conditions are met. You may object to processing based on legitimate interests for reasons relating to your situation. Consent can be withdrawn at any time. These rights have legal conditions and exceptions; a request is not limited to options shown in the interface.

We will respond without undue delay, normally within one month, and explain any lawful extension within that period. We may need proportionate information to verify your identity or authority to act for a child. The European Commission’s guidance explains these rights.

Contact and complaints

Contact info@panuma.app or use our support form. Include your account email and the request, without adding a child’s sensitive details to the initial message.

You may complain to a competent supervisory authority without first completing our support process. For the operator in Hamburg, the Hamburg Commissioner for Data Protection and Freedom of Information provides a complaint form. The GDPR also permits a complaint to the authority for your habitual residence, workplace or the place of the alleged infringement. Where Australian privacy law applies, the Office of the Australian Information Commissioner explains the available complaint process.